Overview of the AUC Program: How Did We Get Here and Where Are We Going? 1
Legislative Origins • 2014 Protecting Access to Medicare Act • The “doc fix” legislation created a program that requires physicians to use a CMS-approved tool to consult appropriate use criteria when ordering advanced diagnostic imaging services. • It all sounds so simple….
The AUC Program In Practice Creates a complex process for ordering and furnishing an advanced diagnostic imaging test Clinician consults Decision support Order placed; AUC using number AUC indication Qualified CDSM (Clinical generated from can be Decision Support CDSM overridden Mechanism) Furnishing clinician reports Test Furnished AUC NO DOCUMENTATION NO PAYMENT consultation on claim form 3
Clinical Decision Support Mechanisms • Health care professionals who order advanced imaging tests (SPECT, PET, CT, MR) must consult AUC through a qualified Clinical Decision Support Mechanism (CDSM) • CDSMs are the electronic tools through which clinicians access AUC – Either embedded in EHR or a standalone system
Sites of Service • Clinicians in the following sites will be required to consult AUC: • Independent diagnostic testing facilities • Hospital outpatient departments – This includes the ER • Physician offices • Ambulatory surgical centers
Exceptions • Emergency conditions • Medicare Part A claims • Significant hardships • EHR and/or CDSM vendor issues • Insufficient Internet access • Extreme, uncontrollable events
Outlier Policy Identification of outlier Approximately 5% professionals will These outliers will of providers will be initially be based be subject to prior identified as on consultation of authorization outliers AUC for priority clinical areas
Medicare’s AUC Program Do we really need it? • Quality • Cost • Improvement • Downside Risk Activities — Quality & Cost • Advancing Care Information 8
Imaging Volume Source: Medicare Payment Advisory Commission, March 2018 9
Challenges to Implementation • Which AUC will your hospital or practice select? • Possibility for discordance if more than one AUC is embedded in the CDSM – Winchester et al. (2016) found 52% of 67 ACCF ratings couldn’t be matched to an ACR rating
Challenges to Implementation • The education component is unclear • Providers receive a yellow or red stoplight when ordering an uncertain or inappropriate test – The AUC program does not counsel providers on the clinical indications that are uncertain or inappropriate • Some AUC include cost and radiation icons, leading to concerns regarding test substitution
Timeline • CMS regulations indicate an educational and testing year to begin in 2020 • This testing phase will address outstanding technical coding and billing concerns • CMS will not deny claims if they do not contain the proper AUC consultation information • CMS has acknowledged uncertainty regarding whether claims without AUC consultation implementation information will be paid • CMS will issue clarifying language in May 12
Recommend
More recommend
